First Name | Gary |
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Last Name | Dalton |
Email Address | gary.dalton@itslb.com |
Affiliation | International Transportaion Service, Inc |
Subject | CHE Ammendments |
Comment | Marine Terminal Operators should not be required to adjust, set-aside, or re-engineer very expensive and mission critical CHE units in order for manufacturers to continue to bring their products up to the operational emissions standards of the State and POLB. It is our position that manufactures have pre-maturely introduced products into the market in a rush to obtain market share when in fact many of these emissions control products have not been fully vetted within the Marine Terminal environment. It is also our position that additional funding must be made available and additional time allotted to both Marine Terminals and manufacturers for achievement of requisite real-world compliance and performance testing. To date this has not been the case. The Ammendments as proposed would let manufacturers continue to transfer responsibility for full vetting of products to the end user. Finally, we request that CARB and the State of California give full and serious consideration to adjustments to the proposed amendments as outlined in the PMA’s June 20th letter to the California Air Resource Board. |
Attachment | www.arb.ca.gov/lists/cargo11/9-its_letter_carb_9.19.11.pdf |
Original File Name | ITS Letter CARB 9.19.11.pdf |
Date and Time Comment Was Submitted | 2011-09-19 16:58:28 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.